FTC’s Click-to-Cancel Rule: What This Means for Subscription Consumers

The court just ended a rule that would have made canceling subscriptions as easy as signing up for them.

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit struck down the Federal Trade Commission’s Click-to-Cancel rule just days before it was supposed to take effect.

If you’ve ever tried to cancel a gym membership, streaming service, or software subscription only to find yourself stuck in an endless maze of phone calls, retention offers, and deliberately confusing cancellation flows, this rule was supposed to fix that problem.

Now it’s gone.

But before you panic about being trapped in subscription hell forever, there’s more to the story. Here’s what happened, what it means for you, and what rights you still have when it comes to canceling unwanted subscriptions.

What Was the Click-to-Cancel Rule?

The FTC finalized the Click-to-Cancel rule in October 2024 under then-Chair Lina Khan. The rule was designed to crack down on what the FTC called “dark patterns,” deliberately deceptive design tactics companies use to make canceling subscriptions as frustrating as possible.

The rule would have required companies to:

1. Make cancellation as easy as signing up. If you signed up with three clicks, you should be able to cancel with three clicks.
2. Provide clear disclosures before billing you, including the price, that it auto-renews, and exactly how to cancel.
3. Get your express informed consent before charging your card.
4. Stop immediately when you cancel. No more charging you for “one more billing cycle” after you’ve already clicked cancel.
5. Ban misrepresentations about subscriptions, like claiming something is “free” when it’s actually a trial that auto-converts to paid.

This rule applied to virtually all subscription services: streaming platforms, gym memberships, software subscriptions, meal kit deliveries, dating apps, everything.

It was supposed to take effect on May 14, 2025, but the FTC delayed enforcement to July 14 to give companies more time to comply. Then, on July 8, the court struck it down entirely.

From a consumer perspective, this rule made perfect sense. Companies happily let you sign up in seconds, but force you through bureaucratic nightmares to cancel.

Why Did the Court Strike Down the Rule?

This is where it gets technical. But, it’s important to understand: the court did not say the rule was a BAD idea or that companies should be allowed to trap you in subscriptions.

The court struck down the rule on procedural grounds, meaning the FTC itself did not follow the proper legal process when creating it.

Here’s what happened…

Under federal law, when the FTC proposes a rule with an economic impact of over $100 million, it must conduct a preliminary regulatory analysis that examines alternative approaches and cost-benefit considerations.

But during the rulemaking process, an administrative law judge determined the rule’s compliance costs would actually exceed $100 million. At that point, the FTC should have gone back, conducted the required preliminary analysis, and reopened the comment, but it didn’t.

The Eighth Circuit ruled this was a fatal procedural error. The court emphasized that letting the FTC skip this step would "open the door to future manipulation of the rulemaking process," where agencies could deliberately lowball economic estimates to avoid proper scrutiny.

Translation: The court essentially told the FTC, "You might be right, but you didn't do the paperwork correctly, so start over."

What Rights Do Subscription Consumers Still Have?

Okay, so the Click-to-Cancel rule is gone, but it was not the only law protecting consumers from subscription traps.

Here’s what still protects you:

1. The Restore Online Shopper’s Confidence Act (ROSCA)

ROSCA has been federal law since 2010. It applies to subscriptions and automatic renewals sold online and requires companies to:

1. Clearly and conspicuously disclose all material terms before getting your billing information
2. Obtain your express informed consent before charging you
3. Provide a simple mechanism for you to stop recurring charges

Violations of ROSCA can result in civil penalties of up to $51,744 per violation, plus consumer refunds. The FTC has been aggressively enforcing ROSCA even after the Click-to-Cancel rule was struck down.

2. Section 5 of the FTC Act

The FTC has broad authority under Section 5 to take action against unfair or deceptive business practices. This includes subscription schemes that trick consumers, hide cancellation options, or misrepresent terms.

The FTC can use this authority to go after companies with predatory subscription practices, even without the Click-to-Cancel rule.

3. State Automatic Renewal Laws

Many states have their own automatic renewal laws that are often stronger than federal requirements. California, New York, Illinois, Virginia, Colorado, Connecticut, Massachusetts, and several other states have laws regulating subscriptions.

These state laws vary significantly, but if you live in a state with strong consumer protection laws like California, you’re likely covered by requirements similar to what the Click-to-Cancel rule would have imposed.

The FTC Is Still Enforcing Subscription Rules Aggressively

Even without the Click-to-Cancel rule, the FTC hasn’t stopped going after companies with predatory subscription practices. In fact, the agency ramped up enforcement in 2025.

Recent FTC Actions:

Chegg, Inc. (September 2025)

The FTC announced a $7.5 million settlement with educational technology company Chegg for making it unreasonably difficult to cancel subscriptions. The settlement also requires Chegg to provide a cancellation process as simple as enrollment - exactly what the Click-to-Cancel rule would have required.

Uber (April 2025)

The FTC sued Uber for allegedly enrolling customers in its Uber One subscription without proper disclosures, failing to obtain informed consent, and using a complicated cancellation process that often didn’t work.

Amazon (Multiple Actions)

The FTC has taken action against Amazon for making Prime cancellation difficult, requiring customers to navigate through retention offers and multi-step processes.

Settlement orders have required Amazon to simplify cancellation and clearly disclose auto-renewal features.

FTC Chair Andrew Ferguson made the agency’s position clear. “Americans are tired of getting signed up for unwanted subscriptions that seem impossible to cancel. The Trump-Vance FTC is fighting back on behalf of the American people."

These enforcement actions show that even without the Click-to-Cancel rule, the FTC still has plenty of legal tools to force companies to make cancellation easier.

How to Protect Yourself from Subscription Traps

Since companies can still make cancellation harder than necessary, the easiest way to avoid forgotten subscriptions is to use a service that tracks them for you. Chargeback’s AI agents automatically scan your email and bank accounts to identify every recurring charge, including free trials that are about to convert to paid subscriptions.

And if you’re having trouble with the cancellation process, Chargeback can help you by doing all the grunt work and getting your subscription cancelled.

The Bottom Line

The Click-to-Cancel rule would have been a game-changer for consumers tired of subscription traps. It would have forced companies to make canceling as simple as signing up. Now that it's been struck down, we're back to the previous patchwork of federal and state laws.

Companies that trap you in subscriptions with deceptive tactics, hidden cancellation options, or unreasonably difficult processes are still breaking the law. The Click-to-Cancel rule is gone, but consumer protection hasn't disappeared.

The best defense? Stay vigilant about what you're signed up for. Use tools like Chargeback to automatically track and manage your subscriptions.

Your money, your choice. Don't let companies trap you in subscriptions you don't want.

Try Chargeback and take control of your subscriptions with AI that automatically finds, tracks, and cancels unwanted recurring charges.

FAQs about FTC’s Click-to-Cancel Rule

How can I avoid subscription traps?

Use subscription tracking tools like Chargeback to automatically monitor all your recurring charges and cancel unwanted subscriptions. Use virtual credit cards for free trials. Set calendar reminders before trial periods end. And always read the fine print about auto-renewal terms before signing up.

Could the Click-to-Cancel rule come back?

Possibly. The FTC could appeal to the Supreme Court or redo the rulemaking process with the required preliminary analysis. However, current FTC leadership dissented from the original rule, so it's unclear whether they'll pursue either option.

Is the FTC still enforcing subscription rules?

Absolutely. The FTC has been aggressively enforcing ROSCA and bringing actions against companies with predatory subscription practices. Recent settlements with Chegg ($7.5 million) and lawsuits against Uber and Amazon show the FTC is still prioritizing this issue.

What laws still protect me from subscription traps?

The Restore Online Shoppers' Confidence Act (ROSCA) still requires clear disclosures, informed consent, and simple cancellation for online subscriptions. Section 5 of the FTC Act prohibits unfair and deceptive practices. Many states have their own automatic renewal laws with additional protections.